Danzl+v.+North+St+Paul

Kelsey Cirmotich Samantha Knight Joann Wagner  Danzl v. North St. Paul-Maplewood-Oakdale Independent School District No 622 706 F. 2d 813 United States Court of Appeals, Eighth Circuit Submitted December 13, 1982 Decided May 4, 1983 Appellee – Agnes A. Danzl V. North St. Paul-Maplewood-Oakdale Independent School District   ** __Summary: __ ** <span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">On May 28, 1980, Agnes Danzl filed a complaint alleging that the school district deliberately favored Jack Edling, an opposing male candidate, for a desired high school principal position. Danzl contended the decision was based solely on gender, and consequently in violation of Title VII of the Civil Rights Act of 1964. Further, the court determined, the School District lacked a legitimate nondiscriminatory reason for hiring Edling. Additionally, the court found that the school district’s reasons for not hiring Danzl were, in fact, pretextual, and therefore, gave weight to the claim that the discrimination was based solely upon her sex. ** __<span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">Decision: __ ** <span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">The pretextual judgment was found to be erroneous based on three findings related to; principal experience, negative references, and intentional discrimination. Originally the court found that the two candidates were equally qualified for the position. Both were qualified; Edling had more practical experience than Danzl, but Danzl held a Ph. D., where Edling only had a master’s degree. However, the superior degree was not listed as a qualification for the position. Also, after the initial selection of candidates, interviews, reference checks, and meetings were conducted. It was not until the final reference checks were obtained, that a recommendation was made for Edling. Several negative references were received for Danzl, where numerous positive results were received on Edling’s behalf. Ultimately, the burden of proof demonstrating intentional discrimination was Danzl’s. Due to the court’s dismissal of Danzl’s previous claim on the same record regarding disparate treatment, the court was questioned whether proper legal principles were applied in the decision of the original case. Ultimately, the school district hired the candidate who was qualified and had positive references and did not violate Title VII. The judgment was reversed. ** __<span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">Impact on Education: __ ** <span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">When Danzl applied to the position there were only a few days remaining in the selection process. Initially, it was noted by the court that “the school district could have investigated her application more intensively or extended the decision-making period…” Perhaps the hiring procedure should be analyzed to limit the potential for liability with regard to claims of discrimination. Had the application deadline been earlier, the school board would have had an adequate amount of time to properly vet all of the applicants and could have possibly avoided the issue all together. That being said, Title VII prohibits discrimination. It does not obligate an employer to hire a minority for a position where all qualifications are otherwise equal among the candidates. ** __<span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">Quiz Question: __ ** <span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">T/F <span style="font-family: 'Times New Roman','serif'; font-size: 12pt; line-height: 115%;">__________Title VII prohibits discrimination and therefore requires that an employer hire a minority when ever possible.